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The National Institute of Standards and Technology (NIST) is seeking comments to improve its Cybersecurity Framework, “Framework for Improving Critical Infrastructure Cybersecurity” (Request for Information available here). The Cybersecurity Framework is a key document providing organizations with standards, guidelines, and best practices to manage cybersecurity risk. With many changes to the cybersecurity landscape since the last update to the Cyber Framework in 2018, NIST hopes to address new threats, capabilities, technologies, and resources. Comments are due by April 25, 2022.
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Continue Reading NIST Seeks Comments on Cybersecurity Framework Refresh

In light of Russia’s recent military actions in Ukraine, the New York Department of Financial Services issued guidance on its cybersecurity and virtual currency regulations. The Department is specifically concerned about heightened risk for Russia’s cyberattacks against Ukraine, which could in turn lead to retaliatory attacks against U.S. critical infrastructure due to U.S. sanctions against Russia.
Continue Reading NYDFS Issues Cybersecurity Guidance in Response to Events in Ukraine

The State Attorneys General in New York and New Jersey recently settled with four companies over alleged HIPAA noncompliance following phishing attacks. The New Jersey settlements were brought against three NJ-based cancer care providers after a phishing attack on several employees’ email accounts. That attack resulted in the unauthorized access of the PHI of 105,200 patients. Although the providers had implemented safeguards, the NJAG concluded that those measures were insufficient to protect against reasonably anticipated threats. In particular, the NJAG was concerned that an accurate and thorough risk assessment had not been conducted, nor was there sufficient employee training. As part of the settlement, the providers agreed to pay $425,000.
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Continue Reading States Catch Health Care Entities Taking the Bait in Phishing Attacks

President Biden recently signed a National Security Memorandum on cybersecurity. This memorandum was required by an earlier executive order, which we previously have discussed here.  The new memorandum (NSM) requires certain network cybersecurity measures for any government information system that is used for highly sensitive national security purposes. The requirements go into effect on a rolling basis over the next 6 months.
Continue Reading White House Focuses on Improving the Cybersecurity of National Security Systems

The Colorado AG recently issued guidance on practices companies should consider to safeguard consumer data. This guidance was issued in response to companies asking what “reasonable” security means. While noting that the standard is a flexible one and calls for case-by-case determinations, the AG highlighted activities it will weigh when making a decision on whether companies are acting reasonably to safeguard information.
Continue Reading Colorado AG Issues Guidance on Data Security Best Practices

Just as we thought 2022 was going to be significantly different than 2021, December 2021 and January 2022 events have thrown us for another (pandemic) loop. We anticipate that some of the privacy and cybersecurity developments from 2021 may similarly repeat in 2022. To help prepare for privacy and cybersecurity program plans for the year, we have created a comprehensive resource of all our www.eyeonprivacy.com posts from last year. From artificial intelligence, biometrics, new US privacy laws, ongoing scrutiny of breach and security issues, to concerns over global data flows, 2021 was a busy year. We have also included several articles focused specifically on managing privacy compliance, and include an examination of right-sized privacy programs, regulatory priorities, and managing “unknown” and unpredictable risks.
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Continue Reading 2021 Privacy Year In Review

As 2021 draws to a close, we wanted to share a recap of some of the most important cybersecurity developments we covered this past year along with some suggestions on what companies (particularly those that do business with the federal government) should expect in 2022. This is part four of a four-part series (you can read Part 1 here, Part 2 here, and Part 3 here.
Continue Reading 2021 Cybersecurity Recap for Government Contractors (and What to Expect in 2022) – Part 4 of 4: Cybersecurity Maturity Model Certification (“CMMC”) 2.0

As 2021 draws to a close, we wanted to share a recap of some of the most important cybersecurity developments we covered this past year along with some suggestions on what companies (particularly those that do business with the federal government) should expect in 2022. This is part three of a four-part series (you can read Part 1 here and Part 2 here).
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Continue Reading 2021 Cybersecurity Recap for Government Contractors (and What to Expect in 2022) – Part 3 of 4: Cyber Incident & Ransomware Payment Reporting Legislation

As 2021 draws to a close, we wanted to share a recap of some of the most important cybersecurity developments we covered this past year along with some suggestions on what companies (particularly those that do business with the federal government) should expect in 2022. This is part two of a four-part series (you can read Part 1 here).
Continue Reading 2021 Cybersecurity Recap for Government Contractors (and What to Expect in 2022) – Part 2 of 4: Department of Justice (DOJ) Civil-Cyber Fraud Initiative